Update on the Nationwide Suspicious Activity Reporting Initiative and Program Management Office

Neighborhood Watch logoIn the fall of 2009, the COPS office printed an article about the creation and execution of the Nationwide Suspicious Activity Reporting (SAR) Initiative (NSI), which discussed the NSI process, the recent conclusion of the Evaluation Environment, and next steps to transition the NSI from a pre-operational environment to a broader nationwide implementation. Since that publication, much has happened to realize these next steps and implement the structure needed for a nationwide rollout of the NSI.

On December 17, 2009, the U.S. Department of Justice was named the Executive Agent to establish and operate the Program Management Office (PMO) for the NSI, taking on responsibility for coordinating existing resources and managing additional support to further develop and deploy the NSI. In March 2010, the PMO was established within the Bureau of Justice Assistance to coordinate the implementation of the NSI through the cooperative efforts of the state and urban area fusion centers and federal partners, and is utilizing standardized process and data structure to make the sharing of SAR information more consistent while maintaining local control of the data.

The goal of the PMO is to facilitate the implementation of the NSI across all levels of government, and assist participating agencies in adopting compatible processes, policies, and standards that foster broader sharing of SARs, while ensuring that privacy and civil liberties are protected in accordance with local, state, and federal laws and regulations. Primary functions of the PMO include advocating on behalf of the NSI, providing guidance to participants at all levels, and coordinating various efforts within the NSI. Given the criticality of privacy and civil liberties issues, the PMO works collaboratively with, and is supported by, the DOJ Privacy and Civil Liberties Office.

NSI PMO Leadership
Thomas J. O’Reilly
is a Senior Policy Advisor for the Bureau of Justice Assistance (BJA), Office of Justice Programs, U.S. Department of Justice (DOJ), and in February 2010 he was appointed Director of the Nationwide Suspicious Activity Report (SAR) Initiative Program Management Office (PMO). Prior to his position at BJA, Mr. O’Reilly was the administrator of the New Jersey Department of Law and Public Safety, the organization responsible for oversight of the state police, emergency management, fusion center operations, criminal justice system coordination, criminal and civil legal services, and juvenile justice.

Matthew Jack was appointed as the Principal Deputy Director on March 1, 2010, joining the NSI PMO from the Department of Homeland Security (DHS) where he was most recently the Deputy Director of the Law Enforcement Information Sharing Initiative at U.S. Immigration and Customs Enforcement.

John O’Neill was appointed as the Deputy Director of the NSI PMO on March 1, 2010. Mr. O’Neill has been with the Federal Bureau of Investigation (FBI) since May 1999, most recently as the Assistant Section Chief of the National Threat Center Section, Counter Terrorism Division.

David Lewis is a Senior Policy Advisor for the BJA and was recently named as the Chief Technology Officer to the Nationwide Suspicious Activity Report (SAR) Initiative (NSI) Program Management Office (PMO), responsible for all the technical aspects of implementing SAR throughout fusion centers nationwide.

Privacy, Civil Rights, and Civil Liberties Protections and Community Outreach
The need to share information through the Information Sharing Environment SAR process  (ISE-SAR) to help protect our hometowns and homeland is of the utmost importance. However, equally important is the protection of personal privacy, civil rights, and civil liberties of all Americans. The NSI has fully recognized this need by developing and implementing a comprehensive NSI Privacy Protection Framework that is required for all agencies prior to participation in the initiative. This framework is composed of three core elements:

  • Privacy policy: The adoption and implementation of an approved privacy policy that contains ISE-SAR privacy protections that are in compliance with required provisions contained in the ISE-SAR Privacy, Civil Rights, and Civil Liberties Protection Policy Template or the Fusion Center Privacy Policy Development: Privacy, Civil Rights, and Civil Liberties Policy Template. It is important to note that one requirement of an NSI program requires sites to have a policy developed and adopted prior to the interstate sharing of ISE-SARs.1
  • ISE-SAR Functional Standard (ISE-SAR FS): The application of the ISE-SAR FS, which reinforces constitutional standards,including the protection of rights guaranteed by the First Amendment and limitations on the use of certain factors—including race, ethnicity, national origin, or religious affiliation—in the gathering, collecting, storing, and sharing of information about individuals.
  • Privacy training: The delivery of privacy training ensures the proper application of the ISE-SAR FS. Three levels of training have been developed for the NSI—chief executive, analysts/investigator, and line officer—all of which include privacy materials.

The success of the NSI largely depends on the ability to earn and maintain the public’s trust. This is accomplished through a transparent process addressing the concerns of citizens and collaboration with advocacy groups. NSI sites are encouraged to engage in outreach to members of the public, including privacy and civil liberties advocacy groups and private sector partners. To support a center’s efforts to interact with their community, the NSI developed and participated in the Building Communities of Trust (BCOT) initiative designed to help centers explain the SAR process, the NSI, and the role of fusion centers to community and advocacy leaders. Further, advocacy groups served an essential role in shaping the NSI Privacy Protection Framework.

NSI Next Steps
The NSI PMO is currently working to implement the NSI process in twelve additional sites, which are expected to be completed by October 2010. Nationwide implementation is expected to be complete in 2012.

For more information on the NSI, visit http://nsi.ncirc.gov/default.aspx , email nsi@ncirc.gov, or call 202-514-9704.

-Katherine Black
Outreach and Communications
Office of the Program Manager for the
Information Sharing Environment


1An ISE-SAR is an official documentation of observed behavior reasonably indicative of pre-operational planning related to terrorism or other criminal activity that has been determined to have a potential terrorism nexus to terrorism.

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